Physician Services Are the Initial Primary Target under Michigan's New Medicare RAC Regime
Wachler & Associates, P.C.
The Centers for Medicare & Medicaid Services (CMS) announced back in October 2016 that it had awarded the next round of contracts to various entities to serve as Recovery Audit Contractors (RACs) for the Medicare program. In total, five separate RAC contractors were awarded, each connected with one of the five designated “RAC Regions.” RAC Regions 1-4 encompass all Part A and Part B provider types, except for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) providers and home health/hospice providers which were consolidated on a nationwide basis under the RAC Region 5 contact. Similar to the previous RACs, the current RACs are contracted to perform post-payment audit reviews in an effort to identify improper Medicare payments (e.g., overpayments) made to providers within the designated RAC Region.
The RAC contract for Region 1, which includes Michigan, was awarded to Performant Recovery, Inc. (Performant). In March 2017, Performant announced on its website that it received approval from CMS to commence audit activity. The specific audit issues to be targeted by Performant, per CMS’s approval, are posted on Performant’s website for providers to access and review. At this time, the majority of the approved audit issues applicable to Michigan target physician/non-physician practitioner services. Examples of these recently approved issues and their descriptions include:
For all approved issues, the dates of service potentially subject to post-payment review by Performant include those claims which have a “claim paid date” within three years or less from the date of Performant’s “Initial Finding” letter (issued to providers following Performant’s audit review). Providers can access the complete list of the currently targeted audit issues under the “Approved Issues” section on Performant’s website. In fact, it is strongly recommended that providers review these approved issues on a regular basis in order to stay abreast of potential audit risk areas.